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EPA Region 6 Pesticide Enforcement Case Resolution

Lean Event Case Study

Summary

EPA Region 6 conducted a Lean value stream mapping (VSM) event in October 2009 to improve the speed and effectiveness of its Pesticide Enforcement Case Resolution Process. Under the Federal Insecticide, Fungicide and Rodenticide Act (FIFRA), EPA is responsible for regulating the sale, distribution, and use of pesticides and prohibits the application of pesticides that are not registered by the EPA. Pesticide enforcement cases are initiated via referrals from within the EPA, state agencies, or the public. Cases resulting in enforcement actions are eventually entered into the Integrated Compliance Information System (ICIS) upon resolution. The goals of the Lean event were to reduce non-value added time in order to increase EPAs ability to close enforcement actions in a timely manner, and to reduce exposure to pesticides by the public. Prior to the Lean event, it took an estimated 455 days from receipt of a pesticide enforcement referral to resolution of the case and entry into ICIS. The excessive time to achieve resolution posed risks of litigation due to the age of violation and potentially extended public exposure to pesticides. With the new process that the team developed, the EPA Region 6 Pesticide Enforcement Case Resolution Process could be reduced to as little as 216 days (53 percent less time).

During the Lean event, the team created a detailed process map of the existing Pesticide Enforcement Case Resolution Process and formulated future state as well as ideal state process maps that aim to greatly reduce delays and total overall timelines. The participants were able to identify seven improvement initiatives that promise to eliminate inefficiencies and waste.

Results

Participants in the Lean event designed a new procedure for the Pesticide Enforcement Case Resolution Process to cut waste and advance the process toward the improved future state developed by participants. With full implementation, the new process is anticipated to yield the following results:

  • Reduced total processing time for the Pesticide Enforcement Case Resolution process from 455 to 216 days (53% reduction).
  • Reduced time spent working on a case that adds value to the product (value added time) from 56 to 46 hours (18% reduction).
  • Increased overall responsiveness to the public and decreased risk to human health and the environment.

The team that participated in the event is actively working together on implementation priorities.  The team’s goal is that the future state process map will be implemented within six months of the event.

Agency: EPA Region 6, Pesticides Section and Office of Regional Counsel

Method Implemented: Value Stream Mapping (3-day event)

Year Conducted: 2009

Consultant Support: NOVACES


Scope of the Lean Project

Project Scope: FIFRA Pesticide Enforcement Case Resolution Process from the time complaints are received until enforcement actions are complete and the ICIS database is updated

Goals

The goals of the event included:

  • Reduce the time each case takes to resolve
  • Reduce public exposure to pesticides

Process Changes and Improvements

During the event, participants developed and analyzed current state, future state, and ideal state maps of the Pesticide Enforcement Case Resolution process, focusing on three major delays along the current state process map which each consisted of over 70 days. These delays were identified as key system constraints. Along with the process maps, participants came up with the following key improvement actions to achieve the future state process.

Region 6 Pesticides Lean Event Case Study Table, 6/4/10

Table 1: Key Improvement Actions and Anticipated Results
Improvement Projected Reduction in Process Cycle Time
1. Implement a policy that the preliminary presentation of all referrals should be conducted at the first Pesticide Enforcement Team (PET) meeting after receipt. 48 days
2. Implement a policy that all cases should be logged in and case file established with 7 days of assignment of Enforcement Officer. 19 days
3. Implement a policy that the assigned Enforcement Officer presents the case not later than the second PET meeting after the case is logged in. 12 days
4. Develop a plan that would increase the number of inspections conducted by the PET. This improvement should reduce the length of delays incurred through the inspection process. 105 days (If all inspections are conducted by PET)
5. Develop a tracking system (Bluebook) to monitor the Enforcement Case Review (ECR) cycle time and facilitate timely follow-up. 40 days (If all ECR are successfully returned within 30 days)
6. Revisit Memorandum of Agreement (MOU) on requirement to request an attorney at greater than $16,500. 15 days*
7. Implement a policy that the assigned counsel will complete their review and attend the Penalty/Calculation Review Meeting within 15 days of the initial PET meeting introducing the referral. 15 days

* This is not included in the total benefits estimate as it is dependent on the revised dollar breakpoint and on the successful implementation of Improvement #7.

Figure 1: Pesticide Enforcement Value Stream Mapping Development

Picture of value stream mapping development

Implementation

As of six months after the value stream mapping event, the Pesticide Enforcement Team has successfully implemented six of the seven identified improvement actions. Because of these changes, enforcement case resolution time has been significantly and consistently reduced. In addition to the process improvements, the team (which included representation from the Office of Regional Counsel) has benefited from the opportunity to come together cohesively to solve problems, and has recognized the value of Lean in helping lay out the pesticides enforcement process. Morale in the Pesticide Enforcement Team remains high as it continues to make process improvements and share its experience with colleagues and management.

For More Information

Contacts:

Wes McQuiddy, EPA Region 6, Chief of Pesticides Section, (214) 665-6722, mcquiddy.david@epa.gov

Terry Sykes, EPA Region 6, Office of the Regional Counsel, Hazardous Waste Enforcement Legal Issues, (214) 665-2158, sykes.terry@epa.gov

William Rhea, EPA Region 6, Special Project Coordinator, (214) 665-6767, rhea.william@epa.gov

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